Technology, Media and Telecoms – Employers’ Year-end Reporting 2024

Now the 2023/24 tax year has ended, employers will need to start thinking about year-end compliance. Whilst many tax year-end employer reporting challenges are sector agnostic, our experience shows that TMT organisations commonly face additional challenges owing to one or more of the following:

An increased focus on dynamic commercial growth over day-to-day compliance;
The absence of staff with employer reporting expertise;
Complex group structures resulting in challenges in oversight and accountability for reporting; and
A desire to reward employees and provide flexibility with how/where they work.

This article considers two of the main challenges that employers experience, and must consider, when completing year-end employer reporting in a timely and efficient manner.

International Workforce

With the lifting of travel restrictions following the coronavirus pandemic, there’s been a significant return to employee travel cross-border for business purposes. Whilst this is a positive from a commercial perspective, allowing global teams to come together and work collaboratively, this can give rise to numerous employer reporting obligations.

Many of the reporting obligations that arise require thorough record-keeping. From tracking travel, documenting trip purposes and understanding assignment policies/processes, employers must ensure they are aligned internally, something which often requires collaboration between different internal/external stakeholders.

Please refer to Table 1 for an overview of the key year-end reporting considerations for employers with an international workforce.

Reward and Recognition

Employers are becoming increasingly innovative when it comes to rewarding employees. This has arisen due to shifting employee priorities, particularly when it comes to focusing on health and wellbeing which has become of increasing importance as employee demographics change. As employers adapt to these demands, the types of benefits they provide, as well as the way they’re provided to employees, is evolving.

As this evolution takes place, it is common for new benefits/rewards to be provided, without due consideration for the subsequent tax and reporting obligations. Furthermore, due consideration needs to be given as to who stands to pick-up any arising income tax and NIC liability.

Please refer to Table 2 for an overview of the key year-end reporting requirements for employers with both formal and informal reward offerings.

Table 1: Year-end reporting considerations for employers with an international workforce

Informal Short-Term Travellers to the UK	Reporting Deadline
EP Appendix 4 – Short Term Business Visitor (“STBVs”) Whilst in many cases, no income tax (PAYE) or NIC liability arises for STBVs, employers must understand travel patterns, along with the purpose of the trip and report this information to HMRC.	31st May following the end of the tax year
EP Appendix 8 - PAYE special arrangement for STBVs Where STBVs don’t qualify under EP Appendix 4, meaning employers are required to file a return to settle any UK income tax liability.	31st May following the end of the tax year
Formal UK Outbound assignments	Reporting Deadline
EP Appendix 5 – Net of Foreign Tax Credit Relief This applies to employers required to deduct foreign tax, in addition to UK PAYE, from the salaries of employees who are sent to work abroad.	31st May following the end of the tax year
EP Appendix 7B Modified Class 1 NICs for employees assigned from the United Kingdom (“UK”) to work overseas.	31st May following the end of the tax year
Formal UK Inbound assignments	Reporting Deadline
EP Appendix 6 Applies to employers who have agreed to operate PAYE on a gross-up of cash earnings and non-cash benefits for all employees eligible and has undertaken with the employees to pay any residual UK liability on earnings based on each employee’s self-assessment.	Payment deadline – 22nd April following the end of the tax year (19th April if by post)
EP Appendix 7A This is the Class 1/1A NIC equivalent for employees included on the EP Appendix 6.	31st May following the end of the tax year

Table 2: Year-end reporting considerations for employers with both formal and informal reward offerings

Payrolling Benefits*	Reporting Deadline
Subject to registering with HMRC, employers can elect to process certain taxable non-cash benefits via the payroll. A proportion of the benefit should be processed via the payroll, based on the number of pay cycles (e.g. monthly/weekly) in the tax year. Employees will then be subject to income tax on the amount reported within the tax year the receive the benefit. Please note, employers must continue to file a Form P11D(b) to account for the Class 1A NIC arising on the benefit. Please see below for further details.	Registration – Prior to the start of the tax year. Reporting – On a per pay cycle period.
Form P11D/P11D(b)	Reporting Deadline
As an alternative to payrolling benefits, employers can instead report all non-cash benefits provided to employees following the end of the tax year. Under this approach, the employer completes a Form P11D for each employee who received a benefit. Employers must then reconcile the total amounts paid on Form P11D(b) and calculate the Class 1A NIC due. When preparing these forms, employers must ensure they: Gather all the data from the various external vendors; Complete the correct calculation of the reportable value – something which can vary depending on the type of benefit; Identify available exemptions/reliefs to reduce the reportable value; and Report the correct figures on the Forms P11D and P11D(b). This is of particular importance for those employers who report some benefits via the payroll. Provide the P11D to each employee.	6th July following the end of the tax year.
PAYE Settlement Agreement (“PSA”)	Reporting Deadline
In some cases, employers may elect to settle the income tax and NIC arising on taxable non-cash benefits on the behalf of the employees. Such cases often include staff entertaining and staff gifts. In these cases, employers can apply for a PSA with HMRC which will reference certain types of benefits. HMRC will only accept benefits on a PSA which are considered minor, irregular or impracticable to be otherwise reported. Reporting costs on a PSA is expensive for employers as it requires both income tax and NIC to be settled on a grossed-up basis. Employers must also ensure that they: Gather all the data required for review and ensuring nothing is omitted; Review the large swathes of data in a consistent and timely manner; Ensuring those with the relevant expertise are involved in the analysis process; and Maximise the application of any exemptions, with due consideration for the conditions that apply to each exemption.	There is no statutory deadline for the calculation. Payment deadline – 22nd October following the end of the tax year (19th October if by post)
Employment Related Securities (“ERS”)	Reporting Deadline
Employers that operate a share plan or, where there has been any type of transaction in shares or other securities, including the grant of options and RSUs, involving UK employees or directors during the tax year, will be required to submit ERS return(s) to HMRC. In preparing the returns, employers must consider the following: Ensure the correct template has been used for the type of transaction that occurred in the tax year; Avoid data formatting errors which can result in HMRC’s gateway rejecting the returns; Consider the impact of foreign exchange rates where calculating the reportable amount; and Ascertain whether any overseas workdays during the tax year impact the reportable amount.	6th July following the end of the tax year.
*Please note, from April 2026, HMRC have announced the abolition of Form P11D reporting. From this date forward, there will be a mandatory requirement to report all non-cash taxable benefits via the payroll. Further guidance is due from HMRC on the practicalities of this change in reporting.

Additional Reporting Considerations

Reporting Requirement

Reporting Deadline

Gender Pay Gap Reporting

Private sector employers with an employee headcount over 250 are required to publicly report gender pay information every year. Failure to provide this information can lead to public naming and shaming by HMRC, causing significant reputational risk.

Challenges with the reporting centre around:

Understanding which data needs to be included in a report;
How, where and when to report the information; and
Preparation of an effective ‘narrative’ to explain any gap(s) which are identified.

4th April following the end of the tax year

Form P60

Employers must provide employees with a summary of the total amount of income tax withheld on their earnings from employment, during the tax year.

31st May following the end of the tax year.